Case Digest (G.R. No. 171655) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case at hand involves the Petition for Review on Certiorari filed by the Heirs of Spouses Gervacio A. Ramirez and Martina Carbonel, represented by Cesar S. Ramirez and Elmer R. Aduca (hereinafter, the Petitioners), against respondents Joey T. Abon and the Register of Deeds of Nueva Vizcaya. The petition was directed against the Decision dated July 29, 2015, and the Resolution dated February 15, 2016, rendered by the Court of Appeals, Former Fourteenth Division in CA-G.R. SP No. 132961. The original subject of the dispute pertains to Original Certificate of Title No. T-4480, which covers a 1,266-square meter lot situated in Barrio Sta. Lucia, Bagabag, Nueva Vizcaya. The title was registered in the names of the deceased spouses Gervacio Ramirez and Martina Carbonel.
The conflict began on May 30, 1978, when Angel Abon (father of respondent Joey Abon) requested the Register of Deeds to issue a new owner's duplicate of the original title on the grounds of a "Confirmati
Case Digest (G.R. No. 171655) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Registration and Subject Property
- The subject property is a 1,266-square meter lot (Lot 1748) located in Barrio Sta. Lucia, Bagabag, Nueva Vizcaya.
- The Original Certificate of Title (OCT No. T-4480) is registered in the names of the late spouses Gervacio A. Ramirez and Martina Carbonel.
- The Transactional Background and Creation of the Duplicate Title
- On May 30, 1978, Angel Abon, father of respondent Joey Abon, requested the Register of Deeds (RD) to issue a new owner’s duplicate of OCT No. T-4480.
- The request was supported by a document titled “Confirmation of Previous Sale” (CPS) which allegedly evidenced the sale of Lot 1748 by the spouses Ramirez to Angel Abon.
- Angel Abon subsequently used the new owner’s duplicate to segregate a 135-square meter portion (designated as Lot 1748-A) from the original lot.
- A Transfer Certificate of Title (TCT No. T-50359) was issued covering just the 135-square meter subdivision.
- Initiation of Litigation by the Heirs of the Spouses Ramirez
- In June 2013, the petitioners (Heirs of the Spouses Ramirez) received a copy of the CPS and became aware of respondent Abon’s potential use of the CPS.
- They filed a complaint in the Regional Trial Court (RTC), Branch 27, seeking:
- Annulment of the CPS on the ground of forgery.
- Issuance of another owner’s duplicate of OCT No. 4480.
- Damages and a preliminary mandatory injunction.
- The RTC dismissed the complaint motu proprio for lack of jurisdiction.
- The petitioners then filed a certiorari petition (docketed as CA-G.R. SP No. 131624) before the Court of Appeals (CA), Fourth Division.
- On May 2, 2014, the CA rendered a Decision denying the petitioners’ certiorari petition for lack of merit.
- A subsequent Motion for Reconsideration was also denied via a Resolution on September 29, 2014.
- Respondent Abon’s Petition for Reconstitution
- On July 5, 2013, respondent Abon filed a petition for the reconstitution of the lost owner’s duplicate of OCT No. 4480 before RTC, Branch 28.
- Abon alleged that:
- His father, Angel Abon, acquired the lot through the CPS.
- He executed an Affidavit of Loss and duly notified the RD.
- On October 4, 2013, RTC, Branch 28 issued a Decision granting Abon’s petition.
- The Decision ordered the RD to issue a new owner’s duplicate copy of OCT No. 4480.
- The RTC’s Decision became final and executory on November 19, 2013.
- Petitioners’ Subsequent Petition for Annulment of Judgment
- On December 3, 2013, the Heirs of the Spouses Ramirez filed a Petition for Annulment of Judgment under Rule 47 before the CA, Former Fourteenth Division (docketed as CA-G.R. SP No. 132961).
- Their central contention was that:
- The CPS did not specify the exact area sold.
- The inscription on the OCT still identified the spouses Ramirez as the owners of Lot 1748, excluding only the 135-square meter portion now under TCT No. T-50359.
- The RTC, Branch 28 lacked jurisdiction in granting the reconstitution petition due to failure to notify the true registered owners (i.e., the Heirs of the Spouses Ramirez).
- Procedural History Leading to the Supreme Court
- The CA, Former Fourteenth Division, in its assailed Decision, denied the Petition for Annulment of Judgment as lacking merit.
- Feeling aggrieved, the petitioners filed their Motion for Reconsideration which was likewise denied.
- Consequently, the instant appeal reached the Supreme Court seeking review of the CA’s ruling and the lower court’s jurisdictional shortcomings.
Issues:
- Whether the CA, Former Fourteenth Division erred in denying the Petition for Annulment of Judgment filed by the Heirs of the Spouses Ramirez.
- Whether the Regional Trial Court (Branch 28) acquired jurisdiction over the petition for reconstitution of the lost owner’s duplicate certificate of title given that:
- The proper notice and public posting requirements, as mandated under Section 109 of Presidential Decree No. 1529 (PD 1529), were not fully complied with.
- The registered owners (the Heirs of the Spouses Ramirez) were not notified of Abon’s petition notwithstanding their status as the record owners of the subject property.
- Whether the failure to notify the registered owners, who are deemed as interested parties under the law, amounts to a denial of due process and vitiates the jurisdiction of the RTC in issuing the new duplicate certificate.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)